NBA-ICLE CPD Notice Is Lawful, No Court Has Declared CPD Regime Unlawful — NBA Ikorodu Vice Chairman Abiodun Counters ABLIF

The Vice Chairman of the Nigerian Bar Association (NBA) Ikorodu Branch, Olajide Abiodun, has stated that the Continuing Professional Development (CPD) compliance notice issued by the NBA Institute of Continuing Legal Education (NBA-ICLE) is lawful, prudent, and non-coercive.

Abiodun, who is also the Chairman of the Human Rights Committee, made the clarification in a statement on Sunday in response to the CPD compliance reminder issued by the NBA-ICLE and a subsequent counter-notice circulated by the Advocacy for Bar Licence Freedom (ABLIF) claiming that a court has ordered status quo on the matter.

Abiodun stated that the NBA-ICLE notice reminding lawyers to complete a minimum of five CPD Units before March 31, 2026, is purely advisory and administrative.

“It neither introduces a new policy nor imposes any immediate sanction. It simply restates an existing requirement under the extant Rules of Professional Conduct and provides ample notice to members. Such reminders are routine in professional bodies and do not amount to enforcement,” he said.

Addressing ABLIF’s claim that a status quo order has been issued by a court, Abiodun explained that such an order does not automatically prohibit administrative reminders or internal communications.

“A subsisting court order to maintain the status quo does not automatically prohibit administrative reminders or internal communications, unless the order expressly restrains such acts. Courts are clear that parties are restrained from altering the res or enforcing disputed sanctions, not from continuing normal administrative operations or informing members of existing obligations,” he stated.

“Until and unless a court makes a specific prohibitory order restraining the NBA or NBA-ICLE from issuing notices, receiving CPD records, or maintaining its portal, the Association remains entitled, and indeed obliged, to continue its statutory and professional functions.”

Abiodun emphasised that no court has, as at today, declared the CPD regime unlawful, suspended, or void.

“Pending litigation does not amount to invalidation. The law remains that subsisting rules and regulations continue to operate until set aside by a court of competent jurisdiction. Anything short of this is conjecture,” he said.

The NBA Ikorodu Vice Chairman cautioned that professional advocacy must be careful not to mislead members into assuming that compliance notices are illegal or contemptuous of court.

“Such narratives, if unchecked, risk creating unnecessary anxiety and confusion within the Bar,” he warned.

He concluded: “In summary, the NBA-ICLE notice is lawful, prudent, and non-coercive. Members remain free to comply at their convenience within the stated timeframe, while the courts are allowed to determine the pending suits without pressure or prejudice. That is precisely how respect for the rule of law is demonstrated.”

The NBA-ICLE had earlier issued a notice reminding legal practitioners of their CPD obligations for the current reporting year.

In the notice, the NBA-ICLE stated that to remain in good standing and fully compliant with the NBA Mandatory CPD Rules, every legal practitioner is required to complete and record a minimum of five (5) CPD Hours/Units on or before March 31, 2026.

“For clarity, the annual CPD reporting year runs from 1 April to 31 March. Accordingly, the 2025 CPD reporting period commenced on 1 April 2025 and will close on 31 March 2026. CPD activities completed outside this window will not count toward the current reporting year,” the notice read.

However, the Advocacy for Bar Licence Freedom (ABLIF) issued a counter-notice informing the legal community that the mandatory CPD requirements are currently under judicial review.

In a public notice signed by its National Convener, Hameed Ajibola Jimoh, Esq., ABLIF stated that a court has ordered status quo to be maintained on the matter.

According to the group, the suit with number FHC/ABJ/CS/2241/2025, titled “Christabel Zoe Ayuk & 11 Ors. v. Incorporated Trustees of the Nigerian Bar Association & 4 Ors.,” is scheduled for hearing on January 20, 2026.

“CPD enforcement on hold pending court decision. The legal community is advised to await the court’s ruling on the matter,” the ABLIF notice stated.

The development had created uncertainty among lawyers regarding compliance with the CPD requirements ahead of the March 31 deadline.

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